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VR Agencies: Use of Innovation and Expansion Funds

The following information will describe how some VR agencies have used innovation and expansion (I&E) funds to support innovative activities and models of service delivery. In addition, this document will summarize the Federal requirements regarding the use of Title I funds to support I&E activities and will provide an explanation of the State Plan descriptions that may need to be modified and resubmitted for RSA approval before agencies can implement their innovative activities.

Description of Requirement:

The requirement for VR agencies to spend a portion of their Title I funds on I&E activities can be found in 34 C.F.R. § 361.35. Specifically, there are three types of activities that can be funded:

  1. Development and implementation of innovative approaches to expand and improve the provision of VR services to individuals with disabilities, particularly individuals with the most significant disabilities, including transition services for students and youth with disabilities and pre-employment transition services for students with disabilities, consistent with the findings of the comprehensive statewide needs assessment (CSNA) of the rehabilitation needs of individuals with disabilities under 34 C.F.R. § 361.29(a) and the State's goals and priorities under 34 C.F.R. §361.29(c);
  2. Funding the State Rehabilitation Council, consistent with the resource plan identified in 34 C.F.R. § 361.17(i); and
  3. Funding the Statewide Independent Living Council (SILC), consistent with the SILC resource plan prepared under title VII, chapter 1 of the Rehabilitation Act. The State and the SILC may determine in the SILC resource plan whether to use funds reserved under this section to fund the Council and, if so, the amount of funds to be used.

Most agencies use I&E funds to support the SRC, and many also use these funds to support the SILC. However, far fewer use I&E funds to promote innovative practices which may lead to increasing the numbers of individuals achieving quality employment outcomes and will also help the agencies productively spend funds that may otherwise go unused.

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Ideas for Using I&E Funds:

Following are ways some VR agencies are using their I&E funds. These are simply illustrative examples.

  • One agency developed work-based learning opportunities for Students with Disabilities to include partnerships with new industries in the State in order to offer simulated work experiences for students that will lead to direct employment in skilled jobs with the partnering industry.
  • One agency designed and implemented Virtual/E-Learning modules to support and standardize the delivery of pre-employment transition services to students with disabilities targeting workplace readiness training and instruction in self-advocacy. Implementation of these E-Learning training modules for employment specialists will improve the consistency of students’ skill levels and improve their outcomes.
  • Another agency expanded joint programs with mental health providers to train and certify peers who can provide Vocational Peer Support for individuals with severe mental illness and co-occurring substance use disorders.
  • One agency developed an Integrated Resource Team approach, where the VR agency comes together with partner agencies and supports to craft and jointly own a Job Seeker’s employment goal, to coordinate wrap-around services, and to commit to ongoing collaboration and communication.
  • Several agencies expanded formalized apprenticeships for VR consumers who can benefit from such training opportunities, paid internships, and on-the-job training opportunities, working in collaboration with the American Job Centers in the state and specific employers that commit to hiring individuals with disabilities.
  • One agency developed multiple pilot programs designed to provide peer mentoring for students with disabilities involved in the justice and foster care systems and homeless or housing-insecure youth. The pilots include a focus on increasing family engagement. The agency is working with local juvenile justice centers or the family court system, and the Department of Social Services Children’s Division to provide services for these underserved populations. This agency also partners with CILs, several universities, the Office of Workforce Development, and an employer mentor.
  • One agency partnered with Accenture to address the benefits cliff by designing a pilot and requesting SSA to amend administrative and benefit elements of SSI and SSDI programs for individuals who participate in the pilot. The pilot creates runways to livable wage jobs that will support beneficiaries in jumping, navigating, or avoiding the benefits cliff.
  • Another agency developed a statewide benefits counseling program which was developed to alleviate the fears associated with the loss of health benefits when obtaining employment. Through a collaborative effort with the Social Security Administration, Virginia Commonwealth University, and Maximus, this agency implemented a fee-for-service model to address consumer needs. Services are currently provided by eight vendors whose staff have been deemed certified benefits counselors. This is provided in a range of service delivery that includes basic benefits counseling and more comprehensive services that can be delivered over a period of time throughout the consumer’s case.
  • Several agencies have used I&E funds to develop pilots with specific employers in the State. One agency partners with Sephora, a global leader in prestige retail, and community partner Capability Health and Human Services to deliver an on-the-job training program that leads to full-time placement upon successful completion. The long-term goal is that 30 percent of the company’s workforce will be individuals with disabilities.
  • This agency also partners with The Starbucks® Corporation. In addition to ongoing programs at the roasting plant, the DSU has developed a pre-training program for baristas working in Starbucks retail stores.
  • Several agencies developed new and innovative initiatives that open the door for new employment opportunities for individuals with disabilities, especially those with significant disabilities, through continued investment in and enhancement of VR’s Business Engagement Team to lead innovative business outreach efforts for the VR program.
  • One agency developed a VR Self-Employment guide (www.vrselfemployment.org) that is of great value for self-employment business plans. This website is used as a tool to prepare the VR Counselor and participants for the development of a self-employment business plan. The website is available as a training platform for counselors and a tool and process that counselors and participants can use together during the self-employment exploration and development process.
  • One agency focused on consistent access to interpreter services for consumers who are deaf in rural areas and enhanced accessibility of VR productions and consumer and staff training materials through a staff interpreter to provide remote video interpreting and on-site services to mutual consumers of the VR agency and DHHS.
  • Another agency developed a contract with the Asperger/Autism Network's (AANE) Life Management Assistance Program (LifeMAP). This program provides practical assistance to individuals on the Autism Spectrum and other related conditions. LifeMAP provides intensive, highly individualized coaching by professionals with expertise in both Autism Spectrum Disorder and specific content areas. Coaches focus on identifying and overcoming the specific barriers each client faces so that the clients can increase their levels of independence toward reaching their full potential.
  • Several agencies developed in-service training for VR staff and the staff of partner agencies to improve services for special populations, e.g., persons with Autism Spectrum Disorders, persons with traumatic brain injury, persons with disabilities who have a criminal background, persons with mental illness, youth aging out of foster care, and individuals with disabilities who are recipients of TANF and SNAP.
  • Two VR agencies in one state collaborated with the Division of Developmental Disabilities to develop a customized employment pilot program. It is a cross-agency delivery model that focuses on an individual’s unique strengths, needs, and interests. The pilot promotes the specific abilities of the individual and meets employer needs through flexible strategies. The VR agency is paying for staff training and technical assistance.
  • One agency expanded assistive technology and low-vision rehabilitation services for blind consumers in collaboration with all blindness rehabilitation services partners throughout the state. This agency Promoted access and training in assistive technology through:
    • collaboration with training and equipment loan programs;
    • equipment demonstrations offered at conferences and seminars; and
    • online videos and product dissemination.
  • To enhance engagement with customers, one agency is piloting a texting solution called SARA, an artificial intelligence program that enables ongoing communication between counselors and customers while it documents that communication in the customer’s case file. It is intended to allow VR counselors to more readily and efficiently engage with customers and to help facilitate the provision of information, such as appointment reminders, training activities, and job opportunities, without requiring additional time to document their efforts.

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State Plan Descriptions that May Require Amendment:

Description J - Statewide Assessment

Sections 101(a)(15), 101(a)(17), and 101(a)(23) of the Rehabilitation Act and 34 C.F.R. § 361.29(a) require VR agencies to provide an assessment of the rehabilitation needs of individuals with disabilities residing within the State, known as the comprehensive statewide needs assessment (CSNA).

Description J of the VR portion of the WIOA State Plan must describe the results of this assessment, including:

  • The needs of individuals with the most significant disabilities, including their need for supported employment services;
  • The needs of individuals with disabilities who are minorities and individuals with disabilities who have been unserved or underserved by the VR program;
  • The needs of individuals with disabilities served through other components of the statewide workforce development system;
  • The needs of individuals with disabilities for transition career services and pre-employment transition services; and
  • The need to establish, develop, or improve community rehabilitation programs within the State.

The use of Title I funds to support I&E activities should reflect the needs identified through the statewide assessment process. The justification for I&E activities supported by the assessment may need to be modified, as appropriate, and Description J may need to be resubmitted to RSA for approval if the VR agency wishes to fund new I&E activities. VR agencies should update Description J, as appropriate, if the CSNA were conducted since the submission or modification of the prior State Plan.

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Description B - Waiver of Statewideness

Pursuant to Section 101(a)(4) of the Rehabilitation Act and 34 C.F.R. § 361.25 of its implementing regulations, the State Plan must ensure that services provided by a VR agency will be available in all political subdivisions of the State (see Assurance 3(g) of the VR portion of the WIOA State Plan).

If a VR agency is unable to meet this criterion for any service, RSA must approve a waiver of statewideness meeting the requirements of 34 C.F.R. § 361.26 prior to the initiation of the project or service.

This description must also be updated at any time, as needed, to include any new projects for which the VR agency is required to request a waiver of statewideness. Certainly, I&E projects supported by Title I funds that are not statewide would be among the projects the VR agency must describe in its request for a waiver of statewideness.

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Description L - Goals and Priorities

Sections 101(a)(15) and 101(a)(23) of the Rehabilitation Act and 34 C.F.R. § 361.29(c) require VR agencies to describe the goals and priorities of the State in carrying out the VR and Supported Employment programs.

States must include these updates with each submission (every four years) and modification (every two years) of the VR portion of the WIOA State Plan.

Depending on the use of Title I funds for I&E activities, this description may also need to be modified at any time before such activities can be undertaken.

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Description O - States Strategies

Sections 101(a)(15)(D), 101(a)(18), and 101(a)(23) and 34 C.F.R. § 361.29(d) require VR agencies to describe the strategies/methods used to:

  • Achieve goals and priorities;
  • Support I&E activities; and
  • Overcome barriers to accessing VR and supported employment services.

Strategies involving the support of I&E activities must be updated with each submission (every four years) and modification (every two years) of the VR portion of the WIOA State Plan.

VR agencies should also update this description, as appropriate, if the three-year CSNA was conducted since the submission of the two-year modification of the State Plan or when there are material changes in the strategies used by VR agencies to achieve the goals and priorities identified in Description l. For instance, if I&E activities are being proposed as a new strategy, then this description would need to be submitted.

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Description P - Evaluation and Reports of Progress: VR and Supported Employment Goals

Sections 101(a)(15) and 101(a)(23) of the Rehabilitation Act and 34 C.F.R. § 361.29 (e) require VR agencies to describe:

  • Progress on achieving the goals and priorities identified in Description l, Goals and Priorities, and Description N, Goals and Plans for Distribution of Title VI Funds;
  • Performance on the performance accountability indicators under Section 116 of WIOA; and
  • The use of funds reserved for I&E activities.

Evaluation of progress toward the agency’s goals and priorities, including goals involving the support of I&E activities, must be updated with each submission (every four years) and modification (every two years) of the VR portion of the WIOA State Plan.

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Conclusion

The bottom line is that a VR agency wishing to fund new I&E projects should work closely with RSA to be certain that all necessary State Plan descriptions are resubmitted to reflect these new activities and that all fiscal requirements in both the program regulations and in 2 C.F.R. Part 200 are being addressed appropriately.